2 Customers Corpor ate clients Business partners Governments NGO’s POINT OF REFERENCE
Point of reference for sustainability policiesEmplo yees Expectations Commitment Mat erials Relationship Financial products Services
‘Sustainably Successful Together – our contribution to
sus tain able development until 2020’
, Rabobank formulated the
ambition to support its clients to achieve their ambitions in and
for a sustainable society, and to prioritize financing businesses
that are leaders in sustainable development. To realize these
ambitions indepth knowledge of the absolute and relative per
formance of our business clients regarding sustainable develop
ment is required. As a cornerstone of the implementation of
Sustainably Successful Together, this framework describes the
sustainability policies of the Rabobank Group. It is designed for
all stakeholders of Rabobank including its employees, customers,
corporate clients, business partners, governments, nongovern
mental organizations, and others who have an interest in
Rabobank. The aim of the document is to provide one point of
reference for all sustainability policies. It outlines our commit
ments and the expectations we have of clients and business
partners. It forms the basis of our sustainability standards for
business relationships, and for providing financial products and
Core Policies u Sustainability strategy and core values
uSustainability policies uPolicy implementation uPolicies in a nutshell Theme policies Sustainable Development Policy
Restriction List Initiatives Contact
52Environment Human Rights Labour Standards Anti-Corruption Animal Welfare Biodiversity Gene Technology Investing in Agricultural Commodities Derivatives Land Governance Armaments Industry Biofuels
Cocoa, Coffee & Cotton Extractive Industries Fishery Forestry Livestock Farming Palm Oil Ship Recycling Soy Sugarcane
and core values
Rabobank Group takes its place in society and adheres to
the core values that are embedded in its mission – respect,
integrity, professionalism and sustainability. These core
values determine the way in which we meet the needs of
our customers and clients, and our attitude to our environ
ment and our internal operations.
Sustainability is becoming increasingly important to our clients and to society. We define sustainability as the quality of not being harmful to people, communities, environment or depleting natural resources, and thereby supporting long-term social and ecological balance. There is more awareness that a healthy balance between wealth and well-being is essential to building a sustainable, vital society, and that the best solutions are created through cooperation.
We aim to contribute to economic, environmental and social progress with a view to achieving sustainable development, and to help our clients achieve their ambitions in a sustainable society. Sustainable development is development which meets the needs of the current generations without compromising the ability of future generations to meet their own needs (United Nations Brundtland Commission Report, 1987). As a cooperative bank, we focus our efforts on accelerating sustainable agriculture and food supply worldwide, and on strengthening vital communities. By linking our financial services, expertise and relevant networks to the sustainable ambitions of all our clients, we can be sustainably successful together!
Rabobank works together on the basis of respect, appreciation
Rabobank believes that all its activities must be carried
out with honesty,sincerity, care and reliability.
Rabobank is committed to contributing to the sustainable
development of society in the financial, social and
Rabobank provides its customers with high- quality expertise and facilities. It is committed to maintaining high quality – whenever possible anticipating the future needs of customers – and providing
its services in an efficient manner.
Our sustainability policies outline our commitments and the expectations we have regarding our clients and business partners related to sustainable development. They are aligned with the Rabobank Group’s view of sustaina-bility as described in our Ambition Statement, Code of Conduct and Food & Agribusiness Principles1.
Purpose and scope
The Rabobank Group sustainability policies support our business decision making at all levels and provide a frame of reference for how we want to deal with business opportunities and risks in the context of direct and in direct sustainability impacts. They are applicable to all of Rabobank’s products and services, organizational units, companies of which we hold (partial) ownership and operations in all countries where we do business and in cludes corporate credits, project finance, investments for own account, asset management and private banking.
Our sustainability policies align with the OECD Guidelines for Multinational Enterprises and describe our ambition to neither cause nor contribute to adverse social and environmental impacts. By way of commitments and ex-pectations, our policies address the (potential) direct impacts we could create because of our own operations, as well as the (potential) indirect impacts we could create because of our clients’ activities. The policies outline how we expect to identify, prevent, mitigate and account for sustainability risks and performance of our own operations, and of those of our clients.
1 Rabobank has formulated five Food and Agribusiness Principles: 1) aiming for food safety and food security; 2) using natural resources responsibly; 3) contributing to enabling citizens and consumers to make well-considered choices; 4) treating animals responsibly; and 5) promoting social welfare.
Types of policies
Applicable for all clients
Applicable for specific clients based on industry
Types of policy
There are four types of sustainability policies related to issues, specifically:
• The Sustainable Development Policy is a generic policy that overarches all of Rabobank’s other sustainability policies and is applicable for all our products and services
• Core policies are related to core environmental, social and governance issues and are applicable for all our products and services
• Theme policies are related to thematic issues that we consider to be material for our business
• Sector policies are related to specific socially and environmentally sensitive industries and supply chains
Expectations detailed in the Sustainable Development Policy and in the core policies are always applicable for all clients. The expectations outlined in the theme and sector policies are only relevant for clients operating in these specific sectors, industries or supply chains.
Rabobank has also identified activities the bank does not want to be involved in. It includes processes and the production and trade of specific products. These are described in the Rabobank Restricted Activities List.
Types of policies
Environment Human Rights Labour Standards Anti-Corruption
Applicable for all clients
Applicable for specific clients based on industry
Animal Welfare Biodiversity Gene Technology Investing in Agricultural Commodities Derivatives Land Governance Armaments Industry Biofuels
Cocoa, Coffee & Cotton Extractive Industries Fishery Forestry Livestock Farming Palm Oil Ship Recycling Soy Sugarcane
The Rabobank credit manual contains specific guidelines for the implemen-tation of our sustainability policies. All employees that prepare and conduct approval and/or review of Rabobank clients and transactions are required to use these guidelines to structure client analysis. The implementation of local credit policies, client acceptance tools, and financing conditions is the res-ponsibility of Rabobank management at the subsidiary or local level.
Rabobank limits client assessments to the potential adverse impacts that we and our stakeholders consider to be material. An adverse impact is a nega-tive effect that goes against desired conditions in our policies. We determine materiality based on the impact of issues, relevance over time and on whether a client has the ability to create a direct or indirect impact on socie ty and/or the environment, be it positive or adverse. We also take our clients’ industry and their countries of operation into account.
The Rabobank sustainability policies include binding conditions between the bank and its clients based on potential adverse impacts that we consider to be material. Contractual clauses regarding compliance with our sustaina-bility policies may be inserted into the relevant contracts or letters for pros-pects. Should serious issues that breach our policy and/or international norms and standards not be rectified through engagement, Rabobank may decide to terminate the client relationship.
Compliance with our sustainability policies is reviewed annually via internal reporting, monitoring and client engagement. Given the differences in the nature of the various Group business units, the technical aspects of imple-menting the policy, embedding it into client acceptance procedures and other mainstream business processes, may differ for every business unit.
Engagement with stakeholders for continuous improvement
There is no single, globally applicable sustainable management solution. As issues can vary widely from one region to another, improvements towards sustainability can vary accordingly. Nonetheless, sustainability principles can be applied across different regions and business units. Rabobank is convin-ced that sustainable development can be achieved through the use of new technologies, improved management practices and internationally recogni-zed best practice standards. It is therefore important that we have two-way dialogue with our employees, business partners, clients and other key stake-holders to learn and understand the challenges they face, the innovations in the market and developments in sustainable business operations.
Engagement contributes to our ongoing learning and improvement. It is important to help us identify and create commercial opportunities, to iden-tify and appraise risks, and to have the opportunity to remedy grievances among the Group’s stakeholders.
Engagement with clients to improve sustainable performance
We believe that our goal of helping clients to improve their sustainability performance demands meaningful and proactive engagement. We aim to have constructive dialogue to contribute to improvements for sustainable development, and to share our knowledge and networks with our clients to motivate them to deal responsibly with their sustainability issues. We encourage our clients to implement good practices, including monito-ring and adaptive management, so that they can be responsive to changing conditions, and can avoid or minimize their adverse impacts. We undertake
client assessments and regular reviews to understand the material issues they face, and help them identify and resolve problems with a view to positi-vely influence their sustainability performance and minimize risks. This ap-proach enables us to gradually exclude unsustainable operational practices, and to support our clients improve their sustainability performance, their business success, and their contribution to society in general.
We are aware that the process of implementing sustainable management standards and practices is challenging and takes time. We accept that some clients are more advanced than others in their ability to show significant progress of implementing environmentally and socially responsible manage-ment practices, and of responsible purchasing practices.
If we have reason to believe the client does not comply with the conditions described in our sustainability policies, or that the client shows insufficient progress in integrating sustainability measures in its daily operations, we will engage with the client and ask him/her to submit a time-bound plan descri-bing how he/she intends to improve the practices in the future, including specific goals and credible timescales.
Even with the best policies and practices in place, the Rabobank Group, or one of its entities or business units, may cause or contribute to an adverse impact that it has not reasonably been able to foresee or prevent. If it is identified that the Rabobank Group, one of its entities or business units is causing or contributing to such an impact, the Rabobank Group will endea-vour to remedy or cooperate in the remediation of the situation.
Rabobank has a Groupwide whistleblower policy for employees, including contractors and directors. Our whistleblower program is implemented at regional and/or local level, and all entities within the Group have an external hotline or alternative external reporting mechanism. Whistleblowers can confidentially report concerns via telephone and email to an independent trusted party on a 24/7 basis, and where local legislation permits or prescribes,
they can also report anonymously. All whistle blowers acting in good faith are protected from retaliation. The whistleblower policy is also available to former employees of Rabobank, and a separate complaint channel is availa-ble for clients.
Rabobank aims to be accountable for developing the right sustainability policies and the right application of this Sustainability Policy Framework. This means that Rabobank:
• formulates policies, standards and procedures on how to maintain, develop, implement and monitor the Sustainability Policy Framework
• deems its Sustainability Policy Framework to reflect materially relevant issues
• is responsive to stakeholder issues that affect its sustainability perfor-mance and takes care that its response occurs through decisions, actions, performance and communication with internal and external stakeholders
• accepts accountability to those on whom it has an impact and who have an impact on it, while stakeholders participate in developing and achieving an accountable and strategic response to sustainability.
Responsibility and review
The responsibility for the delivery of the Rabobank sustainability policies is that of all Rabobank employees, with the ultimate responsibility resting with the Executive Board. However the management of the business units of Rabobank Group is responsible for appraising the policy issues in their own markets and for taking appropriate steps to ensure that clients meet our policy requirements. This includes engagement with clients and affected parties.
Policies in a nutshell
Sustainable Development Policy
This policy identifies how we intend to contribute to economic, environmen-tal and social progress, with a view to achieving sustainable development.
Our clients are expected to know and take into account the potential impact of their activities on the environment and seek to avoid or, when avoidance is not possible, minimize these impacts. They are expected to have appropriate policies and programs to prevent and mitigate adverse impacts.
All clients are expected to respect and promote human rights as described in the United Nations Declaration of Human Rights in their business decisions, and are expected to use their influence with their suppliers to do the same. For unavoidable adverse impacts, they are expected to provide for and cooperate in remediation through legitimate processes.
All clients are expected to respect and promote labour standards as described in the International Labour Organization Declaration on Fundamental Principles and Rights at Work and related conventions. They are expected to do so in their own operations, and to use their influence with their suppliers to do the same. For unavoidable adverse impacts, they are expected to provide for and cooperate in remediation through legiti-mate processes.
Rabobank is committed to applying high standards of honesty and integrity consistently across our global operations and in all our business dealings. We operate according to our corporate values and are committed to preventing corruption and bribery in all its forms and do not tolerate it in our business or in those with whom we do business.
Rabobank uses a comprehensive framework for the assessment of animal welfare based on scientific knowledge and leading and globally accepted best practices and standards. We have strict guidelines regarding animal testing, the use of wild animals and for sponsoring of cultural events. Clients are expected to comply with, among others, the good practices as outlined by the International Finance Corporation’s Good Practice Note Animal Welfare in Livestock Operations, and with the terrestrial and aquatic animal health codes of the World Organization of Animal Health (OIE).
Clients are expected to not damage, cause or contribute to the conversion of high conservation-value areas, nor should they operate in legally protected areas, UNESCO World Heritage sites and RAMSAR wetlands unless the develop ment is legally permitted and consistent with recognized management plans for the area. They are expected to not cause or contribute to a net reduction in the population of endangered species, nor intentionally introduce alien species. They are also expected to be effi-cient with natural resources and conduct (independent) ecological impact surveys and assessments.
Rabobank strongly believes that the application of gene techno-logy can significantly contribute to the solution for future social problems regarding food security, public health, and the development of en-vironmentally sustainable production processes. Rabobank clients are expec-ted to responsibly manage the application of gene technology and consider the interests of the community with great care, and to communicate openly.
Investing in Agricultural Commodity Derivatives
Rabobank is of the opinion that the derivatives market plays a vital role in offsetting price risk and in price discovery, and in providing access to instruments that can offset growing price risks. Rabobank will not engage in proprietary trading in commodity derivatives for pure speculative trading.
Clients are expected to promote good land governance, and implement appropriate governance structures, policies and management systems. They are expected to respect legitimate land tenure rights, and apply inclusive business models and alternative forms of investment that may be more beneficial to existing land users and communities, and that do not require transfer of land tenure. They are expected to engage with stakeholders and maintain open, transparent, effective and accessible mechanisms to record and resolve grievances and disputes.
Rabobank distinguishes five types of controversial weapons: cluster munitions, anti-personnel mines, biological, chemical and nuclear weapons.Rabobank will not provide financial services to companies that are involved in controversial armaments, or that are involved in arma-ments that can be used for controversial purposes. We will also not invest our own funds in any activity that is connected with controversial weapons, or invest in government bonds or securities issued by companies in coun-tries that are subject to sanctions in the form of an armaments embargo, economic sanctions or international travel bans.
Clients are expected to not produce biofuels that contain raw material obtained from land with high carbon stock. They are ex-pected to produce biofuels that provide clear greenhouse gas emission be-nefits after considering the entire lifecycle of raw material compared to fossil fuel. They should ensure that the biomass/feedstock used for the biofuels does not replace (land for) staple crops when there are indications of local food insecurity.
Cocoa, Coffee & Cotton
Clients are expected to take measures to protect biodiversity, safeguard water quality and quantity, use soil management prac-tices that enhance fertility and prevent erosion and degradation, responsibly use, apply and store agrochemicals, and reduce, reuse and recycle waste.
Generally, Rabobank will not provide finance to clients involved in exploration, extraction/mining or production of raw materials or fossil natural resources. It will also not provide finance for the exploration and production of shale gas or other non-conventional fossil natural resour-ces, specifically oil sands, shale oil, shale gas, or coalseam gas, nor for the production or delivery of essential, specifically designed and dedicated servi-ces and assets that are used for the exploration and production of non-con-ventional fossil natural resources.
Clients operate in two types of business – aquaculture or wild catch. Aquaculture clients are expected to safeguard water quality and purchase feed from responsible suppliers. Wild catch clients are expected to become certified under a credible scheme such as that of the Marine Stewardship Council (MSC) and refrain from unauthorized catching and trading of endangered species. Both are expected to apply food standards.
Clients are expected to achieve certification according to the Forest Stewardship Council (FSC) or the Programme for the Endorsement of Forest Certification (PEFC) and to have a purchasing policy that considers sustainability issues for forestry. There are additional expecta-tions for clients that are still working towards certification including to have a time-bound plan.
Clients are expected to take into account local resource availabi-lity (land, water, capital, labour, knowledge, climate and infrastructure), effects of transport (costs, pollution and animal welfare), to minimize emissi-ons, to responsibly use antibiotics, hormones, growth promotants, drugs and other chemicals, and to use sustainably produced feed and sustainable grazing practices.
Clients are expected to achieve the Roundtable on Sustainable Palm Oil (RSPO) certification or verification against the RSPO prin-ciples and criteria based on a time-bound plan. Those in the palm oil supply chain should progressively increase the volume of RSPO certified palm oil as a proportion of the total volume of palm oil entering their supply chains.
Our policy applies to clients working with ships that have more than 500 tonnes gross tonnage. They are expected to adopt best practices, comply with several specific industry regulations identified in our policy. Rabobank will not provide products and services to or procure from businesses whose revenue models include irresponsible and unacceptable recycling practices as a substantial element.
Clients are expected to operate according to industry best practi-ces such as those of the Round Table on Responsible Soy standard (RTRS), e.g., to protect and manage soil and water, not establish plantations on land that has been cleared by fire, document the use of agrochemicals and disposal of chemical waste, and progressively increase the proportion of sustainable soy in their value chain, to respect land tenure rights.
Clients are expected to operate according to industry best practices such as those of the Bonsuco standard, e.g. to refrain from deforestation, to responsibly use agrochemicals and take measures to protect soil, ground and surface water, to respect land tenure rights.
Clients are expected to not be involved in the production and trade of specific products and processes that Rabobank considers detrimental to sustainable development.
22 Rabobank Sustainable Development Policy
Sustainable development is development that meets the needs of current generations without compromising the ability of future generations to meet their own needs. Relevant impacts include, but are not limited to, environ-mental change, poverty and equity, as well as economic, cultural, technolo-gical and political globalization.
Rabobank recognizes that it has the opportunity to create positive environ-mental and social impacts, but that it also has risks associated with the po-tential negative impacts of its own operations and those of its clients. This Sustainable Development Policy is a generic policy that overarches all of Rabobank’s other sustainability policies. The commitments and expectations identified herein are always applicable for all clients, companies of which we hold (partial) ownership, and business partners and are an integral part of our core, theme and sector policies.
In line with our commitment to sustainable development, in our day-to-day activities, and throughout the Rabobank Group we commit to:
• protect and respect the environment, human rights and labour standards • avoid causing or contributing to adverse social and environmental impacts • integrate material sustainability criteria in our business decisions and
• provide products and services that:
- contribute to sustainable development of people, the environment and the economy
- reduce or avoid unsustainable practices - deal responsibly with material impacts
• encourage and support clients to improve their performance in a way that contributes to their business success and to society and the environment • terminate relationships with clients that do not meet the requirements
outlined in our sustainability policies and/or international or national legislation and regulations, and that are unwilling to change the undesired practices within an agreed timeframe
24 Rabobank Sustainable Development Policy
• engage for continuous improvement and promote cooperation between businesses, governments and other stakeholders
• share our knowledge and networks
• foster the development of in-house learning, management capacity and leadership on sustainability issues
• comply with all national laws and regulations in the countries where we operate
• communicate transparently about our vision and activities
• not lend to, or invest in, specific activities and industries as defined in the
Rabobank Restricted Activities List
What we expect of our clients
Rabobank believes that sustainability is not an option but a condition for future prosperity. We aim to positively affect the overall sustainability of our clients’ operations. This implies that the identification of material sustainabi-lity impacts need to be integrated in daily business, and that the impacts of our clients’ activities on society and the environment, and throughout their supply chains, need full consideration in our decision-making processes. Rabobank’s expectations of its clients regarding sustainability align with the OECD Guidelines for Multinational Enterprises and the principles of the
UN Global Compact. We therefore expect them to contribute to economic, environmental and social progress with a view to achieving sustainable development. Our clients should avoid causing or contributing to adverse social and environmental impacts, they should seek to prevent or mitigate an adverse impact when the impact is directly linked to their operations or products and services, and they should account for how they address their actual and potential adverse impacts. This process of identifying, preventing, mitigating and being accountable should be an integral part of our clients’ business decision making and risk management systems. It forms the basis of our implemen tation framework for client assessment and client relations-hip management, and has been consistently applied in all of our sustainabi-lity policies.
The expectations of our clients outlined in this policy are always applicable, regardless of the sector or industry in which they operate.
Specifically, we expect them to:
• not cause or contribute to adverse social and environmental impacts • be aware of their sustainabilitiy risks, including those in their supply chain • use good industry practices
• commit to time bound plans to achieve progression of their sustainability commitments
• adopt mitigation strategies that seek to first avoid, then mitigate, then as a last resort compensate
• implement adaptive mitigation and management measures • influence their supply chain to promote sustainable development2
• be transparent about their risks, commitments, and performance, including adverse impacts
• comply with all applicable local, nationally and internationally ratified laws and regulations and other statutory requirements and be able to show the legality of their operations.
What we expect of our business partners
Rabobank expects its business partners and suppliers to meet the obligati-ons outlined in the Sustainability Statement for Business Partners of the Rabobank and those in our procurement criteria. We monitor our suppliers’ commitment to sustainability by screening and engaging with them. In cases where our suppliers have not met the required obligations, and if ongoing engagement does not lead to improvements over time, we may terminate the relationship on the basis of pre-determined criteria.
2 We recognize that a client’s ability to do this with suppliers will depend on the influence the client has in the supply chain, and its relative size compared to other players.
26 Core policies
The natural environment is all living and non-living things that exist naturally on earth. Relevant risks to the natural environment include climate change, raw material scarcity, natural resource scarcity, water availability, environmental pollution, loss of biodiversity and ecosystems.
Rabobank recognizes that the economic activities of its own operations may have impacts that could threaten the environment. We are therefore committed to a responsible approach to the environment and take into account the consequences of our activities. In addition to our Sustainable Development Policy, with regard to the environment we specifically commit to:
• protect and enhance the environment
• use natural resources efficiently and optimally
• be climate neutral and energy efficient
• use renewable energy sources where possible
• minimize our exposure to clients that could create material adverse social and environmental impact.
What we expect of our clients
Rabobank takes a precautionary approach to assessing the environmental challenges of its clients. Companies that do not effectively address their potential environmental impacts can cause serious long-term and possible irreversible environmental damage, whilst at the same time create significant business risk.
In addition to our Sustainable Development Policy, with regard to the environ-ment we also expect all of our clients to:
• know their potential impacts on the environment, take them into account when making business decisions, and seek to avoid, or when avoidance is not possible, minimize them
• apply industry-specific good operating principles, management practices and best available technologies that do not degrade the surrounding environment
28 Core policies
• when relevant production practices have been codified in globally, nationally or regionally recognized standards, the client should implement management practices to one or more relevant and credible standards, as demonstrated by independent verification or certification
• be aware of the environmental risks in their value chain and limit dealings to those that can demonstrate that they also apply good industry stan-dards and practices. We recognize that a client’s ability to do this with suppliers will depend on the influence the client has in the supply chain, and its relative size compared to other players.
For clients whose activities could potentially create significant impacts, we also expect them to:
• have an environmental policy that reflects their awareness of the risks they have to cause environmental damage
• establish and maintain an environmental management system, including monitoring impacts and implementation of control measures
• assess and address in decision making the foreseeable environmental impacts associated with their processes, goods and services, over their full life cycle.
For clients whose activities could potentially significantly pollute the environment, we also expect them to:
• apply pollution prevention principles and techniques and the most appropriate technologies in the specific circumstances, consistent with good international practice
• to avoid, minimize and control the intensity of the release of pollutants due to routine, non-routine and accidental circumstances with the potential for local, regional and trans boundary impacts
• to have mechanisms in place for immediate reporting of serious accidents and emergencies to the competent authorities.
For clients whose activities have potentially significant3 greenhouse gas
emimissions, we may require that the client consider alternatives and 3 An expected or current production of more than 25,000 tonnes CO₂-equivalent annually.
implement options to reduce direct and indirect emissions. Options may include, but are not limited to product changes to reduce material use, sustainable agricultural practices, material recycling, leak elimination, insulation, cogeneration of heat and power, process changes, and use of renewable energy sources.
30 Core policies
Human Rights Policy
Human rights are universal – to be enjoyed by all people, no matter who they are or where they live. They are described in the United Nations Declaration of Human Rights and related in-ternational law and regulatory frameworks. Relevant issues include rights to adequate housing, food, water and sanitation, rights of indigenous peoples, rights to self-determination, and rights to privacy.
Rabobank recognizes the importance of its role in an international business community, and recognizes that the economic activities of its own operati-ons may risk violating human rights. We respect and uphold the internatio-nal human rights described in the United Nations Declaration of Human Rights, codified in international law4. We are guided by the United Nation’s Guiding Principles on Business and Human Rights, the Respect, Protect and Remedy framework. In addition to our Sustainable Development Policy, with regard to human rights we specifically commit to:
• avoid causing or contributing to adverse human rights impacts
• offer products and services that contribute positively to human rights
• include human rights principles in the process of establishing joint ventures and making acquisitions
• not operate in countries in which we cannot comply with our human rights commitments towards employees and/or where circumstances impede the free choice of business partners
• engage in stakeholder dialogue to identify, assess and remedy grievances, and to ensure ongoing learning and improvement
• remedy or cooperate in the remediation through legitimate processes of any adverse human rights impacts for which we are responsible
• operate a grievance mechanism for all employees and other stakeholders in all countries and business units to address and resolve grievances directly and as early as possible
4 Rabobank recognizes the human rights as codified in the International Covenant on Civil and Political Rights, the International Covenant on Economic, Social and Cultural Rights, the Convention on Elimi-nation of All Forms of DiscrimiElimi-nation Against Women, the Convention on the Rights of the Child, and the UN Declaration on the Rights of Indigenous Peoples.
• fully cooperate in legitimate external processes aimed at addressing and resolving grievances directly and early
• ask, or where appropriate, demand that the companies with which we engage adopt grievance mechanisms to address possible human rights infringements
• assure that the collaborative and multi-stakeholder initiatives in which we participate provide for effective grievance mechanisms and/or other measures of adequate accountability
• ensure that before investing in projects with severe potential human rights impacts, the operation will encompass effective stakeholder engagement, including an operational level grievance mechanism.
What we expect of our clients
Rabobank takes a precautionary approach to assessing the human rights related challenges of its clients. In addition to our Sustainable Development Policy, with regard to human rights we expect all of our clients to:
• respect and uphold all human rights as described in the United Nations Declaration of Human Rights, and related international legislation and regulations
• avoid causing or contributing to human rights violations
• identify, prevent, mitigate and account for any actual or potential adverse human rights impacts that are directly linked to their operations, products and services through business relationships including customers, as well as business associates and society
• be transparent about their risks of causing or contributing to adverse human rights impacts and how they manage those risks
• be transparent about any violations of human rights
• operate effective stakeholder engagement including an operational-level grievance mechanism for any adverse human rights impacts for which they have caused or contributed, and involve affected stakeholders before establishing new operations in a process of free, prior, and informed consultation and duly record the process
• provide for or cooperate in remediation through legitimate processes for violations of human rights that it has caused or contributed to.
32 Core policies
Labour Standards Policy
Labour standards are human rights related to relations between workers and their employers. They are described in various codes and conventions. Core labour standards include freedom of association and the right to collective bargaining, elimi-nation of forced and compulsory labour, the abolition of child labour, and elimination of discrimination in the work place. Other standards that are widely accepted relate to worker conditions such as health and safety.
Rabobank recognizes the importance of its role in an international business community, and that the economic activities of its own operations may risk violating labour standards. In addition to Rabobank’s Code of Conduct, our
Sustainable Development Policy, and our Human Rights Policy, with regard to labour standards we specifically commit to:
• uphold the principles concerning fundamental rights contained in the eight core conventions of the International Labour Organization (ILO) as set forth in its Declaration on Fundamental Principles and Rights at Work5
• respect and encourage diversity in the workplace
• avoid causing or contributing to violation of labour standards
• respect all labour standards of its employees including but not limited to freedom of association and the effective recognition of the right to collective bargaining, elimination of all forms of forced or compulsory labour, effective abolition of child labour, and the elimination of discrimi-nation with respect to employment and occupation
• provide a safe and healthy work environment
• take measures to assert labour standards by means of dissemination of information and training
• promote a corporate culture of awareness of and respect for labour standards
5 Rabobank recognizes the United Nations Convention on the Rights of the Child, the International Labour Organization Declaration on Fundamental Principles and Rights at Work, the International Labour Organization Tripartite Declaration Concerning Multinational Corporations and Social Policy, and the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multina-tional Enterprises.
• provide access to grievance mechanisms that are in line with human rights principles, and through which complaints and disputes can be resolved effectively.
What we expect of our clients
We take a precautionary approach to assessing the labour related challenges of our clients and expect them to uphold internationally recognized labour standards. In addition to our Code of Conduct, our Sustainable Development Policy, and Human Rights Policy, with regard to labour standards we expect all clients to:
• respect all labour standards as described in the ILO Declaration on Funda-mental Principles and Rights at Work
• avoid causing or contributing to violation of labour standards
• respect and encourage diversity in the workplace
• identify, prevent, mitigate and account for any actual or potential violation of labour standards that are directly linked to their operations, products and services through business relationships including customers, as well as business associates and society
• provide a safe and healthy work environment
• apply labour standards considerations in their business decisions
• provide for or cooperate in remediation through legitimate processes for violations of labour standards that they have caused or contributed to
• be transparent about their risks of causing or contributing to violations of labour standards and how they manage those risks
• be transparent about any breaches of labour standards
• operate effective stakeholder engagement including an operational-level grievance mechanism for any violations of labour standards for which they have caused or contributed to
• provide for or cooperate in remediation through legitimate processes for violations of labour standards that it has caused or contributed to. For some clients the potential to cause or contribute to the abuse of labour standards is greater than others. The reasons can be related to the industry and the countries in which the client operates, and/or the level of direct management control or significant influence that they have.
34 Core policies
For clients whose activities have a more significant risk of labour standards abuse, we also expect them to:
• implement good industry practices including a robust and systematic monitoring program that tracks performance
• be aware of the risks in their value chain and limit dealings to those that can demonstrate that they also apply good industry standards and practices6.
6 We recognize that a client’s ability to do this with suppliers will depend on the influence the client has in the supply chain, and its relative size compared to other players
Rabobank is committed to applying high standards of honesty and integrity consistently across our global operati-ons and in all our business dealings. Our values, as stated in our Code of Conduct, guide the way we behave as individuals and the way we do busi-ness. We are committed to preventing corruption and bribery in all its forms and do not tolerate it in our business or in those with whom we do business. We strive to uphold all laws aimed at countering corruption and bribery, including the UK Bribery Act 2010 and the US Foreign Corrupt Practices Act, in all the countries in which we operate. Our policies encourage staff that have any suspicion of bribery or other form of corruption within or related to Rabobank to report this suspicion.
36 Theme policies
Animal Welfare Policy
Animal welfare is the well-being of animals, i.e. the state of animals and how they cope with the conditions they live in. Rabobank believes that good animal welfare implies that an animal is healthy, well-nourished, safe, comfortable, able to express innate behaviour, and that it is not suffering from pain, fear nor distress. Good animal welfare also requi-res disease prevention and veterinary treatment, appropriate shelter, manage-ment, and humane treatment. Animal welfare is an important issue recogni-zed by legislation as well as relevant industry standards and good practices.
In addition to our Sustainable Development Policy and our core sustainability policies, with regard to animal welfare we specifically commit to:
• promote the respect and protection of the well-being of animals based on generally accepted, contemporary, scientific understanding of animal welfare that emerged from the recognition that animals are sentient beings, referencing the following sources:
- the Terrestrial Animal Health Code of the World Organisation for Animal Health (OIE)
- the Aquatic Animal Health Code of the OIE
- the European Convention for the Protection of Animals
- the Animal Welfare Directives of the European Union
- the Good Practice Note: Animal Welfare in Livestock Operations by the International Finance Corporation (IFC).
• encourage clients to act in accordance with Rabobank’s Food & Agribusiness Principles and changing societal expectations as they relate to animal welfare over time to ensure the ongoing sustainability of the industry and our clients’ businesses
• two key principles of animal welfare management. The first, to provide for the needs of animals that are critical to their survival, refers to meeting the basic physical/functional requirements of animals for water, food, shelter, good health and safety in ways that minimise negative experiences such as thirst, hunger, discomfort, pain, fear and distress. The second, the promotion of positive experiences, refers to improving welfare above the survival minimum by providing animals with enriching opportunities to engage in behaviours that increase their comfort, confidence and capacity
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to make rewarding choices. These principles support the contemporary recognition that acceptable animal welfare management should include both the minimisation of negative experiences and the provision of opportunities to have positive experiences
• apply a framework within which animal welfare assessments and decision-making may take place, allowing for differences in local legislation on animal welfare and market practices within animal husbandry to be reflected in the local procedures that will be applied in different geo-graphical regions
• only accept requests for the sponsoring of cultural events with animals, including wildlife species, if it is demonstrated that the above welfare standards are met and that the activity is generally accepted within the community in which it takes place. To this end, the organizer of the cultural event is required to provide Rabobank with proof in the form of an independent expert opinion
• provide support and advice to clients on alternative solutions, where necessary give clients time to implement new standards if they change over time.
What we expect of our clients
We recognize that companies that work with animals can have significant business risk regarding animal welfare issues. We have general requirements for all of our clients that work with animals, as well as specific requirements depending on whether a client works with farmed animals, uses animals for experimental purposes and for the sponsoring of cultural events.
In addition to our Sustainable Development Policy and our core sustainability policies, we expect all clients that work with animals no matter where they operate in the world to also:
• respect and protect the well-being of animals
• be aware of their potential to cause or contribute to adverse animal welfare issues and take precautionary measures to avoid them • follow two key principles of animal welfare management:
- To provide for the needs of animals that are critical to their survival, refers to meeting the basic physical/functional requirements of animals for water, food, shelter, good health and safety in ways that minimise
negative experiences such as thirst, hunger, discomfort, pain, fear and distress
- The promotion of positive experiences, refers to improving welfare above the survival minimum, by providing animals with enriching opportunities to engage in behaviours that increase their comfort, confidence and capacity to make rewarding choices.
These principles support the contemporary recognition that acceptable animal welfare management should include both the minimisation of ne-gative experiences and the provision of opportunities to have positive ex-periences.
• be transparent and account for any animal welfare incidents
• apply the guidance below to working with animals in the following contexts: 1. farmed animals
2. household pets
3. animals used for experimental purposes
4. use of animals for entertainment and cultural events 5. wildlife protection and conservation.
Ad 1. Protection of farmed animals
Rabobank will encourage clients to comply with ‘accepted good practice’ as published by the IFC guidelines in the Good Practice Note: Animal Welfare in Livestock Operations. The accepted good practices are grouped into eight topics. Below is a brief specification of the Rabobank principles on these topics.
• Feed and water: All animals must have access to sufficient feed and water to meet their functional and behavioural requirements. Medicated or enriched food and water should only be used on professional advice or when it is not detrimental to animal health and welfare.
• Proper housing systems: When housing systems are used, they should support the behavioural needs of the animals regarding movement, functional areas, environmental enrichment and resting, as well as non-harmful social habits. The housing system must protect the animals from injury and distress.
• Health and disease: A preventative health care program should be in operation, supported by periodic testing of the animals and remedial action being taken when necessary.
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• Husbandry practices: All husbandry practices used should minimise the distress, injury and pain that animals may experience. In particular, where practicable, alternatives to practices that in their execution cause injury and pain (e.g. dehorning, castration) should be used or pain-relieving measures introduced.
• Transport: Animals closely confined in road vehicles for transport over long distances or for long periods should be off-loaded during the journey at intervals corresponding to driver fatigue breaks, and they should then be fed, watered and rested. The practices used should minimise distress and risk of injury.
• Slaughter: Animals should be handled and slaughtered in the least distressing and most pain-free manner possible. Rabobank recognises that it is necessary to take account of the particular requirements of certain religious rites, such as ‘Halal slaughter’7. In this case, reversible stunning
should be practiced where possible.
• Genetics and breed selection: The choice of breeds and breeding objectives should not focus only on maximum production and/or profit, but should also include animal welfare requirements. In addition, breeds used should have a demonstrated capacity to adapt to the environments in which they are expected to perform.
• Stockmanship: Owners or keepers of animals must look after their animals’ welfare and, as a minimum, ensure that they do not cause any unnecessary pain, distress or other harm. The provision of welfare enrich-ing opportunities should also be included. As animals may be adversely or beneficially affected by the attitudes and behaviour of stockpersons towards them, they should be treated with consideration at all times. Rabobank stresses the importance of and need for appropriate training of all stockpersons and the introduction of motivating incentives to ensure that good management practices are implemented.
7 The religious authority on whose behalf slaughter is carried out shall be competent for the applica-tion and monitoring of the special provisions which apply to slaughter according to certain religious rites. That authority shall operate under the responsibility of the official veterinarian.
Ad 2. Household pets
Most of the areas noted for farmed animals also apply to domestic pets. Specifically, these are feed and water, proper accommodation (housing), health and disease management, genetics and breed selection, and animal care (stockmanship). Of the three remaining, the equivalent of painful husbandry practices, if done, should usually be by a veterinarian, special precautions should apply to long distance transport of pets, and, of course, slaughter is excluded.
Ad 3. Protection of animals used for experimental purposes
In the view of Rabobank Group, experiments on sentient animals must only take place if, after specific evaluation, the purposes of the experiment/re-search (i.e. its anticipated benefits) are considered to be justified. Moreover, a harm-benefit analysis must have shown that the benefits outweigh the harms and that specific attention has been given to maximising the benefits and minimising the harms. Regarding harm minimisation, sentient animals may be used only if suitable methods involving sentient animals or non-animate alternatives are not available. In addition, animals involved must be those with the lowest degree of neurophysiological sensitivity, all procedu-res used must be selected or refined to minimise negative impacts on the animals, and the number of animals used should be the minimum required to achieve the objectives of the work.
These provisions apply to the use of animals for the development, manufac-ture, quality, effectiveness and safety testing of drugs, foodstuffs and other substances or products:
• in treating diseases or health problems in humans, animals or plants • in treating physiological conditions in humans, animals or plants
• for the protection of the natural environment in the interests of humans or animals.
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The Rabobank Group will not fund other types of research on sentient animals. In addition, Rabobank usually will not finance the use of endangered species or primates for experimental purposes, except in limited very specific cases: • if the aim of the experiment/research in question is the preservation of the
• if this species is patently the only one suitable for the biomedical purpose. In the event that, after the experiments have finished, the wellbeing of the animal cannot be guaranteed, it must be euthanized by an approved method, as soon as possible. Persons who carry out experiments or take part in them must be scientifically competent and have the appropriate education and training. Any associated animal breeding, supply and user establishments must be approved by the competent authorities.
Finally, all experiments and research on sentient animals must comply with relevant national and regional laws and regulations.
Ad 4. Use of animals for entertainment and cultural events
There is an ongoing public debate about whether or not animals, including wildlife species belong in entertainment shows in general and circuses in particular. The discussion is centered on two questions. Firstly, whether the welfare of animals kept under these circumstances is sufficiently guaranteed with regard to the minimisation of negative welfare-related experiences and the provision of enriching opportunities that promote positive welfare-related experiences. Secondly, whether keeping animals for entertainment purposes is in itself an acceptable practice. Rabobank will only accept requests for the sponsoring of cultural events with animals, if it is demonstrated that the above welfare standards are met and that the activity is generally accepted within the community in which it takes place. To this end, the organizer of the cultural event is required to provide Rabobank with proof in the form of an independent expert opinion.
Ad 5. Wildlife Protection and Conservation
Rabobank Group will not establish a commercial relationship with clients where evidence has been found of illegal trade in species listed in appendi-ces I and II of the CITES Convention on International Trade in Endangered Species of Wild Fauna and Flora.
Biodiversity is the term used to describe the variety of life found on earth and all natural processes. Damage to biodiversity is considered harmful if the impact is long-lasting or irreversible. Relevant potential adverse impacts include loss, degradation or fragmenta-tion of habitats (modified, natural, and critical), invasive alien species, over-exploitation, hydrological changes, nutrient loading and pollution.
Rabobank believes that sustainably managing living natural resources is fundamental to sustainable development. We recognize that the economic activities of our operations could have impacts that could threaten the envi-ronment, and possibly damage biodiversity and ecosystem services. In addition to our Sustainable Development Policy and our core sustainability policies, with regard to biodiversity we specifically commit to:
• avoid causing or contributing to adverse impacts on biodiversity and ecosystem services
• provide responsible financial products and services to clients that will protect and preserve the integrity of biodiversity and ecosystem services.
What we expect of our clients
Rabobank clients can potentially create adverse impacts on biodiversity and ecosystems, and these impacts can in turn create further impacts on ecosystem services. Degradation and loss of ecosystem services can pose operational, financial and reputational risks for the client and for Rabobank. In addition to our Sustainable Development Policy and our core sustainability policies, with regard to biodiversity we specifically expect our clients to: • know their potential impacts on biodiversity and ecosystem services • not damage, cause or contribute to the conversion of high
• not to operate in national or international legally-protected or preserved areas and areas containing globally, regionally or nationally significant concentrations of biodiversity values
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• not operate in legally protected areas, UNESCO World Heritage sites and RAMSAR wetlands unless the development is legally permitted and consistent with recognized management plans for the area
• not cause or contribute to a net reduction in the population of endan-gered species
• not intentionally introduce alien species and implement measures to avoid the potential for accidental or unintended introductions including via the transportation of alien species
• seek to avoid causing or contributing to adverse impacts on biodiversity and ecosystem services, or when avoidance is not possible, minimize these impacts
• implement a mitigation strategy with a mitigation hierarchy that seeks as a preference to avoid impacts then to mitigate unavoidable impacts, and as a last resort, to compensate for unavoidable residual impacts that remain after avoidance and mitigation measures fail
• implement good industry practices and adaptive management so that implementation of mitigation and management measures is responsive to changing conditions
• execute breeding programs that take into account the quality of life of the animal
• have a policy that reflects the awareness of their risks to cause adverse impacts on biodiversity and ecosystem services
• have management practices, including quantitative targets and deadlines to protect biodiversity.
Gene Technology Policy
Gene technology or genetic engineering directly manipulates an organism’s genome using DNA from bacteria, viruses or other plants and animals. It can be used in agriculture to engineer crops so that they can achieve enhanced nutritional value, show greater resistance and tolerance to insects, dry weather, soil conditions, or the direct application of herbicides or pesticides. Relevant potentially adverse impacts include food safety, food security, environmental damage, consumer choice and labelling.
Rabobank strongly believes that the application of gene technology can offer a solution to the requirement to continue to feed the rapidly growing world population into the long-term future. We expect that gene technology will be able to make a major contribution in the coming decades to solve social problems with respect to food security and public health, and to deve-loping environmentally sustainable production processes. We are aware of the doubts that many still have regarding this technology. For this reason, we believe that great care should be taken in the application of gene tech-nology by all parties concerned, specifically the interests of the community should be handled with care and communication with stakeholders should be open. It is under these conditions that Rabobank is willing to be involved in this technology as a financial services provider.
In addition to our Sustainable Development Policy and our core sustainability policies, with regard to gene technology we specifically commit to:
• clearly state our position with regard to gene technology
• only being involved in those activities with the potential to deliver added value to the users of the products in which gene technology is incorpo-rated and which, at the same time, show due regard for the safety of people, nature, the environment and animal welfare
• evaluate credit applications related to gene technology within their own specific context
• be guided by the degree of transparency in the companies involved when deciding financing gene technology activities
• maintain dialogue with scientists, ethicists, politicians and social organiza-tions.
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What we expect of our clients
Rabobank is aware of and also respects the concern that exists in some parts of the community regarding the possible negative effects of gene techno-logy. In addition to our Sustainable Development Policy and our core sustaina-bility policies, with regard to gene technology we specifically expect our clients to:
• exercise transparency about their activities and aims with regard to gene technology.
Investing in Agricultural Commodities
Agricultural commodities derivatives can be futures contracts, forward contracts, options and swaps of agricultural commodi-ties. They are generally used as an instrument to hedge risk, but can also be used for speculative purposes. The related potentially adverse impacts include a destabilizing effect on the agricultural commodities markets.
Rabobank is aware of the ongoing debate about investing in agricultural commodities derivatives. It is our view that the derivatives market plays a vital role in offsetting price risk and in price discovery. The role of the deriva-tives market is becoming even more important now that the markets are becoming tighter and more volatile, increasing the need for all stakeholders in the food and agribusiness value chain to have access to instruments to offset these growing price risks. We are a leading food and agribusiness bank, and a strategic partner of companies throughout the global food chain. As such, we facilitate value chain participants – our food and agri-business clients – in using the derivatives instruments and market.
In addition to our Sustainable Development Policy and our core sustainability policies, with regard to agricultural commodities derivatives we specifically commit to:
• not engage in proprietary trading in commodity derivatives for pure speculative trading
• ensure that we have sustainable practices in our client and company relationships, as reflected in our Food and Agribusiness Principles8 and the various supply chain policies
• integrate assessment of (material) environmental and social impacts in our investment decision making process and client-lending practices
8 Rabobank has formulated five Food and Agribusiness Principles: 1) aiming for food safety and food security; 2) using natural resources responsibly; 3) contributing to enabling citizens and consumers to make well-considered choices; 4) treating animals responsibly; and 5) promoting social welfare.
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• actively participate in multi-stakeholder initiatives to promote the sustain-ability of commodity value chains such as roundtables for palm oil, soy and sugar, etc
• take an engagement approach with key stakeholders (clients, NGOs, regulators, etc.) to contribute to the understanding of material issues and to affect positive change
• make our clients aware of the risks and dilemmas that apply to agricultural commodity derivatives investing
• facilitate clients that want to invest in agribusiness companies that contribute to food security
• support research and further analysis of the impacts of commercialisation of the agricultural commodities markets, also with a pro-poor emphasis • engage with policy makers and regulators on the long term stability of
agricultural commodities markets and with commodity futures exchanges, investment managers, etc. with the goal of improving governance and transparency of commodity futures and over-the-counter markets towards regulators
• take different measures to prevent a potentially destabilizing effect of our activities on the agricultural commodities markets, aligning with the recommendations of the UN Principles for Responsible Investment and UN Global Compact (2011).